To U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue, S.E. West Building Ground Floor, Room W12

- 140 Washington, DC 20590

Subject Petition for Exemption under Section 333 of the FAA Modernization and Refor m Act of 2012
and 14 CFR Part 11.81 of the Federal Aviation Regulations

Date September 16 , 2015

Petitioner Henry J. Sommer
2378 Nantucket Circle State College, PA 16803
Email: anvilus9@comcast.net

1. Petition
Pursuant to Se ction 333 of the FAA Modernization an d Reform Act of 2012 and 14 C F R Part 11.81, Henry Sommer applies for an exemption from the listed Fede ral Aviation Regulations (FAR ) to al low commercial operation of small unmanned aircraft systems (sUAS) nam ed below for photography, cinematogra phy and photogrammetry applied to inspection of real estate,
construction activities, industrial sites, agriculture and golf courses. All operatio ns will be
conducted under conditions outlined by the FAA in Section 333

.

2

. FAR s ections from which exemptions are requested

a. 14 CFR 21 subpart H
b. 14 CFR 45.23

c

. 14 CFR 61.113
d

. 14 CFR 91 .7

e

. 14 CFR 91 .9
f

. 14 CFR 91 .103

g

. 14 CFR 91 .105
h

. 14 CFR 91 .109
i

. 14 CFR 91 .119 j

. 14 CFR 91 .121
k

. 14 CFR 91 .151
l

. 14 CFR 91 .203

m

. 14 CFR 91 .405

n

. 14 CFR 91 .407

o

. 14 CFR 91 .409

p

. 14 CFR 91 .4173

. Relief requested

a. Henry Sommer propos es to operate sUAS for commercial purposes to include (but not limited to) photography, cinematogra phy and photogrammetry applied to inspection of real estate,
constructio n activities, industrial sites, agriculture and golf courses. This relief is requested
because com mercial use of sU AS is prohibited by FAR unless performed under an exemption.
b. This proposal inc l udes use of the following sUAS , all of w hi ch are battery powered quadrotor
aircraft that weigh less than 55 pounds and have been approved in previous exemptions

. i. DJI Phantom 2 Vision Plus
ii. DJI Phantom 3
iii. 3D Robotics Iris + iv. 3D Ro o botics X8 +

4

. Public benefit

a. Use of s UAS technology to obtain images , information and data currently obtained by manned flight or manual methods:
i. Reduces risk to human life due to manned aircraft accidents and due to other dangerous activities that can be avoided (e.g. ladders, scaffolding

, rigging ) ii. Reduces the cost of obtaining such information, which benefits consumers and the

economy. iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions
from manned aircraft

5 . Precedence

a. Th is application is similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213

. b

. All aircraft and flight operations will comply with conditions and limitations specified in most

recent Grant of E xemption Nos. 12839 and 12845 dated September 14, 2015

.

6

. Safety not adversely affected

a

. All a ircraft will comply with maintenance an d inspection requirements of manufacturer s

. All repair and maintenance work will be conducted following manufacturers' user manuals and will use replacement parts authorized by manufacturers.
b

. Pre

- flight inspections w i ll be conducted prior to each flight.

c

. The Pilot in Charge (PIC) and Visual Observer (VO) will maintain visual line of sight ( VLOS ) with the aircraft at all times.
d

. The PIC and VO will maintain direct verbal communication at all times.

e. Flights will only be conducted in daylight.
f

. Flight s will stay below 400 feet above ground level (AGL)

. g

. Ground speed will not exceed 50 knots.
h. Flights will n ot intrude into Class B, C or D airspace

. i

. Flights will n ot be made near or over persons on the ground without their prior permission. j

. All aircraft have battery level indicators and will not be operated with less than 25% battery capacity

. k . All aircraft have automatic return

- to

- home firm ware that will ac tivate in the event of loss of
radio communication.l . All aircraft have capability for the PIC to abort a flight in case of unpredicted obstacles,

w eather, or emergencies.

Please advise of any additional information or changes that may be required.

Si ncerely,

Henry Sommer